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A borrower visits a mortgage loan originator (MLO) for Mortgage ABC to discuss getting a...

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A borrower visits a mortgage loan originator (MLO) for Mortgage ABC to discuss getting a home equity line of credit (HELOC) loan from Bank LMN. The MLO encourages the borrower to apply with Bank XYZ instead because ABC does not provide HELOC loans. When the borrower submits an application directly to XYZ, XYZ pays the MLO $100 from the 1% origination fee that it collected from the borrower. Is this fee permissible?

A.

The fee is permitted if the fee is disclosed on the final settlement statement.

B.

The fee is permitted as the MLO performed origination services for the borrower.

C.

The fee is not permitted as the MLO did not perform any actual origination services for the borrower.

D.

The fee is not permitted as the MLO did not perform any actual origination services for the borrower, unless the fee was paid directly by the borrower.

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